A Suspicious Activity Report — a SAR — is how the regulated sector tells law enforcement about suspected money laundering or terrorist financing. SARs are the lifeblood of the UK's financial-intelligence system: they flow to the National Crime Agency (NCA), feed investigations, and — through the consent regime — can pause a transaction so the proceeds of crime do not slip away.
What a SAR is
A SAR is a structured report submitted to the NCA when you know or suspect — or have reasonable grounds to — that someone is engaged in money laundering or terrorist financing. It protects the reporter and gives the NCA intelligence it could not otherwise gather.
Who must submit one — and the two routes in
Within a firm, staff report internally to the MLRO, who decides whether to submit an external SAR to the NCA. There are two broad types of SAR:
| Type | Purpose |
|---|---|
| Standard SAR | Reports a suspicion for intelligence — you are not seeking permission to act |
| DAML SAR | Defence Against Money Laundering — seeks consent to proceed with a specific act that would otherwise risk a POCA offence |
How DAML consent works
When proceeding with a transaction might itself be a money-laundering offence, a firm can seek a defence by submitting a DAML SAR. The timing, set by s.335 and s.336 of POCA, follows a fixed clock.
You submit a DAML SAR seeking consent to proceed. Put the stages in order.
- During the moratorium you must not proceed while law enforcement acts
- Notice period: the NCA has 7 working days to respond
- Submit the DAML SAR to the NCA seeking consent to proceed
- After the moratorium ends (if not extended), the prohibition lifts
- If refused within the notice period, a 31-calendar-day moratorium begins
- If no refusal in that time, consent is deemed and you may proceed
The tipping-off trap
Walk the decision
A customer asks to push through a large, oddly-structured payment. You're suspicious. What now?
You suspect the funds may be criminal property. First move?
Quality over quantity
The NCA has long encouraged better, not just more, SARs. A vague, low-information report helps no one; a clear, specific one with the right detail is genuinely actionable intelligence. Good screening and record-keeping make for better SARs.
Where Probitas fits
Probitas does not file SARs — that is a firm's own legal process — but it supports the suspicion-forming stage: by screening names and companies against sanctions, PEP and adverse media sources and anchoring findings to their source, it helps build the evidenced picture that underpins a clear, high-quality report.
Suspicious
What is a Suspicious Activity Report?
A structured report to the National Crime Agency about suspected money laundering or terrorist financing. It provides law-enforcement intelligence and, in regulated firms, discharges a legal duty to report suspicion.
Who do I report a suspicion to?
Within a firm, staff report internally to the MLRO (nominated officer), who decides whether to submit an external SAR to the NCA. The MLRO is the channel to law enforcement.
What is a DAML SAR?
A Defence Against Money Laundering SAR — a report seeking consent to proceed with a transaction that might otherwise be a money-laundering offence. If consent is given (or deemed), the firm has a defence to proceed.
How long is the moratorium period?
If the NCA refuses consent within the 7-working-day notice period, a 31-calendar-day moratorium begins, during which the firm must not proceed. The moratorium can be extended by court order in some cases.
What is tipping off?
Telling the subject (or another person) that a SAR has been or may be made, in a way likely to prejudice an investigation. It is a separate criminal offence for the regulated sector, so SARs must be handled discreetly.
Sources
This guide is written from primary sources. Each is linked below; claims in the text link to the specific reference they rely on.